Pre-Residency Planning for Your Client’s Trust

Domestication in the international context.

Carl A. Merino, Dina Kapur Sanna, Sarah B. Jacobson | Oct 22, 2021

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Trust domestication has become increasingly common for global family trust structures. Whenever U.S. beneficiaries or U.S. settlors are in the mix (including non-U.S. settlors who later become U.S. persons), trust domestication can be critical to avoiding punitive tax rules and compliance headaches. For many foreign grantor trust structures with U.S. beneficiaries,¹ this is the last stage of the foreign settlor’s² succession plan, to be implemented after the settlor’s

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